Hatfield Direct:

1. Good afternoon, Mr. Hatfield. Please introduce yourself to the members of the jury.

-Hello. My name is R.S Hatfield.

2. What do you do for work, Mr. Hatfield?

-I am the president of Mid-Continent, Inc., and have been for the last 25 years.

3. What kind of business does Mid-Continent Inc. do?

-We develop, manufacture, and sell gas additives. These additives help increase the

mileage that vehicles get out of regular gas.

4. Has Mid-Continent, Inc. been successful?

-I’m happy to say that it has. I’ve seen this company grow to be a $10 million

corporation.

5. What makes Mid-Continent so successful, do you think?

-I would say in part, it’s because Mid-Continent was the first in the field to come up with

something like STP.

6. Can you explain to the members of the jury what STP is?

-STP is a gas additive that works extremely well. We trademarked it in 2003. We were

the first company to develop the formula, and no one’s product since has worked as well

as ours.

7. How did you develop this formula for STP?

-We invested about $1.5 million developing our product. In fact, we were the first

company to start using benzopyrene in a gas additive in January of 2015.

8. What is benzopyrene?

-It’s an organic compound.

9. Because you were the first company to start using benzopyrene, was it important to you

that the formula remained a secret?

 -Yes. Mid-Continent treated all of our research projects, including the use of

benzopyrene, as top secret. We did this to maintain the competitive advantage over

other companies, who didn’t know about it yet.

10. Are you familiar with a woman named C.W. Block?

-Yes. I met Block several times when she worked for us.

11. Did you ever speak with Block?

-Yes, a few times. I can specifically remember one time in late March of 2016. We were

at a company cocktail party. It was a conversation about raiding and industrial

espionage. Block acknowledged my concerns and mentioned that that’s precisely why

she was happy to sign the confidentiality agreement. She said that in terms of her loyalty

to the company, I had nothing to worry about. I specifically recall her saying “This is my

home. I intend to stay here for the rest of my career.”

12. Why do you remember that sentence specifically?

-I remember them because I was so touched at the time. But Block ended up leaving the

company just 4 months after saying she never would.

13. Where did Block go after leaving Mid-Continent?

-She went to go work at Track Oil.

14. Are you familiar with Track Oil?

-Of course. They sell PSSST, which is a knock-off of STP. They’re out chief competitor.

They are always sniping at us, trying to get some unfair advantage.

15. How did you interpret Block leaving Mid-Continent for Track Oil?

-I was shocked. She was the first employee that we’ve ever lost to Track. My only

explanation is that they’re paying her for more than just her employment.

16. What did you do after Block left Mid-Continent?

-I was concerned about Block maintaining our company’s trade secret about

benzopyrene, so I wrote Track Oil a letter expressing my concerns. I also included the
 Conflict of Interest and Confidentiality agreement that Block had signed when she

worked at Mid-Continent.

17. Why did you include these agreements with your letter?

-I wanted Track Oil to know that their new employee was legally bound to keep our trade

secrets, so that they wouldn’t tempted to ask her about them. I guess that didn’t work.